As a authorized operator in Italy, we gather and safeguard personal and transactional data under rigorous legal obligations. This policy details exactly how long we retain different categories of information, the legal reasons behind those periods, and the security measures that shield your data at every stage. We regularly balance our duty to retain records for fraud prevention and financial audits with the privacy rights you possess under Italian data protection law and the GDPR. Our schedules undergo regular reviews so we keep fully compliant.
Legal Grounds for Record Keeping
Our data management policy rests on several legal obligations that govern gambling operators serving the Italian market. Anti‑money laundering rules from the Italian Financial Intelligence Unit require us to keep activity logs, identity verification documents and suspicious activity reports for a specific duration after the business relationship ends. Meanwhile, tax rules administered by the Agenzia delle Entrate require we preserve financial records that back up taxable gaming revenue and player winnings. These obligations override any general right to erasure during the mandatory period. For operational data that isn’t covered by a fixed legal window, we rely on legitimate interest assessments where a valid reason exists, and we allow an opt‑out unless a compelling legal obligation overrides it.
Storage with Consent
Marketing preferences, newsletter sign‑ups and the behavioural analytics employed for personalised offers stay only with your explicit consent. You can withdraw consent anytime through your account dashboard; once you do, we halt that processing immediately and delete the connected profiles within thirty days. Data processed lawfully before withdrawal is removed from active systems to block further use, but it is not removed https://www.repubblica.it/giochi-e-scommesse/superenalotto/2024/03/05/news/estrazioni_superenalotto_la_combinazione_di_martedi_5_marzo-422259032/ retroactively. Consent records themselves are kept for six years as proof of compliance. We never employ this data for anything beyond the activity you agreed to.
Information Erasure Procedures
When a information type hits the end of its scheduled retention, our automatic lifecycle system kicks off a safe removal process. First, the data gets digitally detached from production databases. Next, physical storage blocks are overwritten with random data patterns to hinder forensic recovery. Finally, a cryptographically timestamped entry lands in a audit trail, giving verifiable evidence that erasure happened on time. Backup copies rotate every ninety days, so any deleted data vanishes from all media within three months. When a litigation hold applies, we pause the deletion workflow only for the affected records, note the hold reason, and restart once the hold lifts.
Data Security In Retention
Retained data is secured with AES‑256 encryption at rest, TLS 1.3 protocols in transit and isolated virtual private clouds. Access necessitates multi‑factor authentication plus just‑in‑time privilege elevation that expires on its own. Every access event is logged into an immutable audit trail. We run quarterly penetration tests through CREST‑certified firms and continuous vulnerability scans to maintain our storage tight. Backups are encrypted and spread across Italian data centres, with strict controls that block accidental restoration of data past its deletion date. A dedicated lifecycle dashboard marks every dataset as it nears expiration.
Access Control and Staff Training
Only employees whose roles demonstrably need access to retained personal data get permissions, and those permissions go through monthly recertification audits. Any access to dormant user records initiates a managerial review within one business day. Every staff member who handles personal data completes mandatory annual training on Italian data protection law and our internal retention policies, including hands‑on exercises on spotting valid erasure requests and distinguishing the difference between data we must keep under a legal hold and data we can delete straight away.
Affiliate Program Data Retention
Affiliate partner information, including communication data, payment details and commission payment history, remains for the life of the active partnership plus a decade after the partnership concludes. That stems from tax requirements on commission transactions, which necessitate long‑term financial records. Affiliate performance statistics and aggregated referred‑player statistics get anonymised after half a decade. We explicitly prohibit affiliates from separately gathering or retaining personal information about referred players; they receive only anonymous, combined statements. Our affiliate contracts include inspection rights to check adherence, and any breach is cause for prompt contract ending and commission loss.
Data Categories and Holding Times
We sort all user data into clear categories, each connected to a retention schedule that corresponds to its use and legal context. That structured approach keeps us from keeping things forever. Every year our Data Protection Officer assesses these categories and updates the timelines whenever new guidance arrives from the Garante per la protezione dei dati personali. Below you’ll find how long each data type remains in our live systems before being securely de-identified or destroyed. Archived backups operate on a ninety‑day cycle because of technical limitations.
Identity and Monetary Records
Identity documents you submit during Know Your Customer checks, like passport scans, utility bills and tax ID numbers, stay on file for ten years after you close your account, as anti‑money laundering law mandates. Deposit and withdrawal logs, payment method tokens and wallet balance histories are retained for ten years from the date of each transaction, satisfying both AML requirements and Italian Civil Code limitation periods. We keep these records in encrypted, access‑restricted vaults and tamper‑proof ledgers. Once the retention deadline expires, we remove all personal identifiers permanently; statistical trends may still be utilized but never in a way that links back to any individual.
Account Activity and Support Communications
Comprehensive records of game sessions, bets placed, outcomes and session lengths are kept for five years after each gaming event, matching the statute of limitations for civil disputes. Customer service transcripts, email threads and call recordings stay for three years from your last interaction, covering the typical complaint‑handling window. After those periods, raw logs and case attachments get permanently deleted. Aggregated, anonymised datasets can be kept indefinitely for product improvement and service quality analysis. All of this data lives in case management systems with role‑based access restrictions.
Ethical Play and Self‑Exclusion Data
When you activate self‑exclusion, your identity data must be stored permanently in a locked‑down register to stop you from opening new accounts, a measure Italian gambling regulations explicitly permit. Other safer‑gambling markers, like expired voluntary deposit limits, are deleted two years after the limit lifts. We never use self‑exclusion register data for anything other than enforcing the exclusion. The register is completely walled off from marketing and operational systems, so it serves only its protective purpose.
Cross-border Data Transfers and Data Retention
Our main systems resides inside Italy and the larger European Economic Area. Some supporting services, like fraud https://www.fanpage.it/stile-e-trend/moda/alessandro-cattelan-truccato-dalla-figlia-si-e-papa-anche-col-rossetto-la-felicita-e-nelle-piccole-cose/ detection platforms and customer relationship tools, may pass some personal data to countries external to the EEA. In those cases, we ensure an adequacy decision is in place or we establish Standard Contractual Clauses in place together with a transfer impact assessment. The retention periods we use to transferred data reflect those in this policy, and processors are contractually bound to erase or return data when the service ends. We keep a public register of sub‑processors, updated within fourteen days of any change, and we choose vendors with Italian data centres. Geo‑fencing rules maintain Italian user data inside European boundaries, validated through yearly audits.
Policy Changes and User Notifications
We assess this Data Retention Policy every six months and whenever a major legal change hits Italian gambling operations https://it-richroyal.it/legal-and-affiliates/. Minor clarifications go up silently with a revised effective date. Material changes that modify retention periods, include new data categories or alter the legal basis for processing are communicated directly to you by email at least thirty days before they come into force. You’ll also find an in‑platform banner notification when you log in during the notice period. Historical versions are archived and available on request, each with a version number and a validity date range. If an earlier version gave a shorter retention period for certain data, we adhere to that promise for data collected under that version and apply new terms only going forward.
Individual Rights and Retention Management
When you file an erasure request, our system automatically reviews each data category against its retention schedule. Anything past its mandatory window is erased without delay. For data still subject to a legal retention obligation, we secure it right away so it’s taken out of active use and stored only for compliance storage; we inform you which specific law applies and the date deletion becomes possible. Access requests are handled within thirty days and come with a breakdown of what we keep, why, and the scheduled deletion date. If you question accuracy, we attach a note instead of changing the original record, so the audit trail is preserved. Portability requests are fulfilled in a structured, machine‑readable format even while data is still in its retention window.
Frequently Asked Questions
Is it possible to ask for data deletion prior to the retention period’s conclusion?
Certainly, you can submit a deletion request at any moment. We instantly examine each data category in relation to its legal retention duty. If there’s no legal hold, we delete it fast. For anything we must keep, we restrict it to storage‑only, tell you the legal basis stopping immediate deletion and give you the expected deletion date. You can also view all your data categories with their scheduled deletion dates through your account dashboard. This partial method honors your rights to the extent permitted by Italian regulations.
What occurs with my data when I opt for permanent self‑exclusion?
If you sign up for permanent self‑exclusion, your personal data is shifted to a dedicated exclusion register that operates indefinitely with highly restricted access. This is a legal mandate designed to stop you from creating new accounts. Your gameplay and transaction history, on the other hand, still follow the standard retention schedules and get deleted once those periods run out. The self‑exclusion record is separated from all marketing and operational platforms, so it only serves the safeguarding role it was intended for. No promotional communications will reach you.
What is your approach to data from inactive accounts?
After twelve uninterrupted months of no login, an account is considered inactive. At that point, we automatically switch off marketing communications and move the account to a dormant state with reduced processing. The underlying retention periods remain active according to the original data collection dates, not the date of inactivity. That means data from an inactive account is still held for the full statutory period that applies to its category and then deleted according to our standard procedures. If you come back after a long break, you might need to complete a fresh Know Your Customer check to reactivate. The current status is always visible on your data dashboard.
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